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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a complete inspection of the Bowie Mine No. 1 conducted by <br />Tony Waldron of DMG. The first day of the inspection the inspector <br />was accompanied by Basil Bear of Bruin Mining Company. The second <br />day the inspector was unaccompanied. The mine is active and is <br />permitted to produce 600,000 tons of coal per year from the west <br />mine and 1 to 1.5 million tons per year from the main mine. <br />The inspection began by reviewing repair work that has been <br />performed on the sedimentation pond series 1-4. These are the <br />binwall ponds that were the subject of notice of violation C-95-012 <br />which was issued for failure to maintain the above mentioned <br />sediment ponds. The problem was that the ponds were leaking a <br />fairly large volume of water through the binwall embankments and <br />their associated discharge structures; thereby, compromising the <br />ponds ability to treat disturbed area runoff. <br />In order to correct this problem the operator retained a contractor <br />to pressure inject polyurethane foam (PUF) into the downstream <br />binwall of ponds 2, 3 and 4 through 3/4 inch holes at pre-set <br />intervals of approximately four square feet. The objective was to <br />fill any voids with the PUF and eliminate water piping through the <br />embankment. From observations of the completed work it appears <br />that a significant amount of material was injected into the <br />embankments. The PUF had clearly exited the binwalls at a number <br />of places where water was observed piping through the embankments <br />during spring runoff events. The ponds will be inspected during <br />upcoming precipitation events to determine the effectiveness of the <br />repair plan. <br />The inspection continued at the west mine area where considerable <br />activity has occurred this past summer and fall to clean up and <br />organize the surface equipment storage area. The traffic areas <br />have been graded out and the surface drainage systems were well <br />maintained. The sediment pond contained water below the discharge <br />level. <br />The loadout was inspected and no problems were noted. The west <br />coal storage area pond was holding a small amount of water below <br />discharge level. Partial clean-out maintenance had been performed <br />on this pond earlier this fall. The east sediment pond was dry and <br />stable. Very little coal is currently being stored on the ground <br />at the loadout and almost all of the coal at the west storage area <br />has been shipped out. <br />The inspection continued on 11/30/95 beginning at the ROM coal <br />stockpile and the timber storage area. The surface water drainage <br />systems were in good condition and the sediment pond was holding a <br />